Sanitation and preventing contamination

#Contamination prevention

How do I identify risk areas for contamination?

There are several scenarios that you might flag as at risk for contamination. Areas we often flag include:

  • Facility co-storing organic and conventional ingredients
  • Reuse of containers that store organic and non-organic product
  • Sanitization of equipment and surface areas
  • Areas where prohibited materials are stored or applied
  • Equipment used for both organic and non-organic products

What do I need to know if I use a shared kitchen space?

If you use a commercial kitchen, or shared kitchen facility, you must communicate with all other users to identify their practices and materials (e.g., sanitizers) that require actions to prevent contamination. If multiple operations are producing organic products in a shared kitchen, consensus on pest control prevention methods and cleaning methods can help everyone and create consistency.

What are some contamination prevention strategies?

Each operation will need to meet unique needs with appropriate contamination prevention strategies. The first step is to take plenty of time to create best practices for higher risk areas. Common strategies for prevention include:

#Prevention of ingredients commingling

What is commingling?

Commingling is defined as the contact of organic products with non-organic products.

What are some risk areas for commingling?

In particular, split operations (operations that handle both organic and non-organic products) are at much higher risk for commingling.

Areas we often flag include:

  • Facility co-storing organic and conventional ingredients
  • Reuse of containers that store organic and non-organic product
  • Equipment used for both organic and non-organic products

What are some strategies to prevent commingling?

Each operation will need to meet unique needs with appropriate commingling prevention strategies. Start by identifying your risk areas and actions. Common strategies for commingling prevention include:

  • Clear designation of storage areas for organic products
  • Clear and consistent labeling
  • Staff education and awareness
  • Plans for elimination and removal of cleaning and sanitizing residue
  • Dedicated equipment for organic products

Resource

Check out WSDA’s Preventative Practices for Organic Handlers video for examples of commingling prevention.

#Equipment

Can I use my equipment for both organic and non-organic products?

Yes. However, you’ll need to demonstrate and document a plan for purging and sanitizing equipment to prevent the commingling of organic and non-organic products.

When do I need to purge my equipment?

Purging applies to equipment used for both organic and non-organic products. It may also eliminate the step of equipment cleaning in certain situations.

A purge runs an adequate batch of organic product through equipment to eliminate any residue or remaining non-organic product in unreachable areas. All purged organic batches may not be sold as organic. They are eligible for sale as non-organic or may be discarded. Detailed records of equipment cleaning and purges are required.

Tip

Always purge shared equipment prior to running a full organic batch.

When are equipment purges not required?

If you can adequately clean equipment prior to an organic run, or you are an organic-only facility, a purge is not required. Appropriate steps to eliminate cleaning material or sanitation residue are still necessary.

#Pest management

Which forms of pest control are allowed for my organic operation?

The USDA National Organic Program requires preventative pest management practices as a first measure in any area where organic products are handled, processed, or stored.

Commonsense pest prevention practices include:

  • Removing potential habitat and food sources for pests
  • Preventing pest access to the area where you work with organic product
  • Controlling environmental conditions (e.g., temperature, light, etc.) to stop pest reproduction

What do I do if pest prevention methods are not enough?

If prevention methods are unsuccessful, you are eligible to use certain mechanical controls, such as traps, light or sound.

What do I do if pest prevention and mechanical methods fail?

Only after pest prevention and mechanical methods fail can you look to approved materials as a means for pest control. Never use a material unless it is approved for use per the National List and/or until after OTCO review and approval.

Some examples of National List approved materials include:

  • Carbon dioxide
  • Nitrogen
  • Vitamin D3 bait
  • Boric acid
  • Diatomaceous earth
  • Soap products

Under what circumstances can I use synthetic pest controls?

In rare scenarios where prevention, mechanical controls, and approved materials do not work, only then may you consider synthetic pest control methods. You will need OTCO approval prior to use.

To review your desired pest control method, we’ll need:

  • Photocopies of the product label
  • Manufacturer safety information sheet
  • Demonstration of the need for use and documentation of failed preventative, mechanical and approved material pest control methods
  • Clear plans for contamination prevention and documentation plan
  • Updates to your Organic System Plan under pest management

Send information about all of the above to your client service team for review.

#Storage

Can I co-store organic and non-organic products?

Yes. This is considered a “split operation,” or a facility that handles organic and non-organic products in one location.

When storing organic and non-organic products, you must prevent all organic product(s) from coming into contact with prohibited materials (e.g., sanitizers, pest control substances, etc.) or from commingling with non-organic product(s).

Can I store organic products in a non-certified facility?

If your product is packaged or sealed in a container and clearly labeled prior to storage, you may be able to use a non-certified storage facility. Your product can’t be processed while on-site at the non-certified facility. This includes no repackaging, relabeling, or introducing atmospheric modifiers such as ethylene.

The non-certified storage facility must fill out an Independent Storage Information Sheet.

Forms & Documents

Download the above and submit it to your client service team.

#Transportation

Alert

All transporters of organic livestock are subject to different certification requirements.

What do I need to know about storage during transport?

If you’re sending your product in a large container, you’ll need to provide verification that all cleaning methods of the container follow organic guidelines.

If you’re sending or receiving your product in permeable containers such as boxes or clamshells, you must provide verification from the shipping agent that it is protected from encountering prohibited gases, liquids, or materials.

Do I need to use a certified transporter?

No. You don’t need to use a certified organic transporter provided your product is sealed and clearly labeled prior to transporter receipt. It cannot be repackaged, relabeled or processed in any way — including use of restricted atmospheric controls — throughout the time of transport.

#Sanitizer materials and restrictions

Alert

COVID-19 Update:

There is no evidence of food or food packaging being associated with the transmission of COVID-19. And while the U.S. Environmental Protection Agency has shared a list of disinfectants for use against coronavirus, we understand it’s confusing to know what is allowed as a certified organic operation. Please read below for more info on what’s permitted.

Are there restrictions if my organic product doesn’t come into contact with sanitizers?

You can use any sanitizer, disinfectant, or cleaner on food contact surfaces and equipment as long as it does not leave a residue or contact organic products.

If you use a sanitizer that leaves a residue, you must thoroughly remove the residue by rinsing equipment with clean water — alcohol-based sanitizers must be air dried — before running organic products.

What materials can I use when my organic product will come into contact with sanitizers?

Any sanitizer that may contact an organic product (such as no-rinse sanitizers used on food contact surfaces, or wash water additives) must be approved for use in organic.

For sanitation practices due to COVID-19:

  • COVID-19 sanitizers that are organic-approved and EPA-listed include: hydrogen peroxide, peroxyacetic acid, sodium hypochlorite, and hypochlorous acid; isopropanol and ethanol are approved for sanitation during post-harvest handling activities.
  • You can use OMRI-listed sanitizing products, following all restrictions, immediately.
  • There is no documented evidence of food-based transmission of COVID-19.

We’ve created a list of Oregon Tilth approved sanitizers, cleaners, and disinfectants for your reference. Please note, use of an approved product must still follow all restrictions (if any). Please notify your client service team if you need to add non-OMRI listed products to your inputs list.

OTCO List of Approved Sanitizers

What are the requirements for quaternary ammonium compounds (quats or QACs)?

The high lingering residual effects for quats make them efficient and effective sanitizer solutions. However, quats are prohibited from coming into contact with organic products, ingredients, or packaging. You must perform a thorough rinse or alternative, acceptable intervention to remove them from surface areas and equipment.

Following removal, you must use a low-ion test strip to verify no quat residue is present. Your procedures and test results must be documented. Testing does not need to be performed each time provided you maintain — and record — the necessary pressure, temperature, quantity, and timing of the rinse as found in the initial, zero residue test result. However, you must periodically test the efficacy of your procedures and provide ongoing documentation that your contamination prevention process is still effective.

OTCO currently accepts the following test kit results:

  • LaMotte, 2934 Insta-TEST Dual Range QAC Test Strips
  • Micro Essential Lab QL-110 Hydrion Lo Ion Quat Test Kits

Note

All sanitizers and cleaners are part of your Organic System Plan (OSP). If you need to make a change to your sanitation process, follow our process for adding (or removing) approved materials prior to use.

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